ASU 2025-06

What is ASU 2025-06?

ASU 2025-06 is a FASB accounting update that modernizes how companies capitalize internal-use software costs under ASC 350-40. It replaces project stages with a probable-to-complete threshold.

Updated November 2026 · 6 min read


ASU 2025-06 is an Accounting Standards Update issued by the Financial Accounting Standards Board (FASB) in September 2025. Its full title refers to targeted improvements to the accounting for internal-use software, and it changes the rules in ASC 350-40 that determine when companies can capitalize the costs of building software for their own use. For any organization that develops software internally, from custom business applications to internal platforms, the update affects how much development cost appears on the balance sheet and how much hits the income statement.

The main reason for the change is that the old rules were written for a linear, waterfall style of development. They tied capitalization to project stages that rarely match how software is built today, with iterative, agile methods and continuous delivery. ASU 2025-06 removes those stages and replaces them with a principle-based threshold, which is intended to make the rules easier to apply to modern development practices.

Definition of ASU 2025-06

ASU 2025-06 amends ASC 350-40, the US GAAP subtopic covering internal-use software. Internal-use software is software acquired, developed or modified solely to meet an entity's internal needs, with no substantive plan to market it externally. The update changes when costs for such software begin to be capitalized, and it also moves website development guidance into ASC 350-40.

The update does not change the accounting for software developed to be sold, leased or otherwise marketed, which remains under ASC 985-20. It also does not change the basic idea that capitalized software is amortized over its useful life once it is ready for its intended use.

Removal of Project Stages

Before the update, ASC 350-40 divided internal-use software projects into three stages: a preliminary project stage, an application development stage and a post-implementation stage. Costs in the preliminary and post-implementation stages were expensed, while qualifying costs in the application development stage were capitalized.

ASU 2025-06 removes all references to these stages. Many organizations found the stages hard to apply to agile projects, where planning, design, coding and testing happen continuously and in short cycles. Without stages, companies no longer need to decide which phase each sprint or release belongs to.

The New Capitalization Threshold

Under the update, an entity begins capitalizing software costs when two conditions are met. Management, with the relevant authority, has authorized the project and committed to funding it, and it is probable that the project will be completed and the software will be used to perform its intended function. This is often described as the probable-to-complete threshold.

When evaluating whether completion is probable, an entity must consider whether there is significant development uncertainty. The update describes two factors: whether the software involves novel, unique or unproven technology, functions or features whose uncertainty has not yet been resolved through coding and testing, and whether the performance requirements are not yet clearly defined or are still changing significantly. If significant development uncertainty exists, capitalization is deferred until it is resolved.

Importance of ASU 2025-06 in IT Financial Management

Software development is a large and growing share of technology spending, and capitalization decisions affect how that spending is reported. Moving costs from operating expense to capital spreads them over future periods through amortization, which changes reported profit, budgets and key metrics.

The update therefore matters to CFOs, controllers and IT finance leaders, as well as to engineering leaders whose teams must track the time and costs that may be capitalized.

Simpler Application to Agile Development

The removal of project stages addresses a long-standing difficulty for organizations using agile methods. Under the old rules, finance teams often had to map sprints and backlogs onto a waterfall framework, which required judgment and created inconsistencies between companies.

The new threshold focuses on management commitment and the probability of completion, which can be assessed at the project or initiative level. This should make capitalization decisions more consistent and easier to document, although judgment is still required, especially when assessing development uncertainty.

Effects on Reported Results

Depending on how an organization applied the old rules, the update could increase or decrease the amount capitalized. Projects with significant development uncertainty, such as experimental or novel software, may see capitalization start later than before, increasing expenses in early periods.

Changes in capitalization affect the amount recorded as amortized cost on the balance sheet, the capex vs opex split of technology spending, the size of amortization in future years, the IT budget and metrics such as operating income and EBITDA. IT finance teams should model these effects before adoption so that budgets and forecasts reflect the new rules.

How to Implement ASU 2025-06

The update is effective for annual reporting periods beginning after December 15, 2027, including interim periods within those years, and early adoption is permitted at the beginning of an annual reporting period. That gives organizations time to prepare, but changes to processes and systems can take longer than expected.

Implementation typically involves finance, IT finance and engineering leadership working together to update policies, tracking and reporting.

Updating Policies and Tracking

Organizations should revise their software capitalization policies to reflect the new threshold, including how they will document management authorization, funding commitment and assessments of development uncertainty. Clear criteria help ensure decisions are consistent across teams and projects.

Time tracking and project accounting systems may need changes. Many organizations already track developer time by project to support capitalization, and the new rules may allow simpler tracking because sprints no longer need to be assigned to stages. Disclosures also change: capitalized internal-use software costs follow the property, plant and equipment disclosure requirements in ASC 360.

Choosing a Transition Method

The update allows three transition methods. Under the prospective method, the new rules apply to costs incurred after adoption for all projects, including those in progress. Under a modified prospective method, the rules apply to new costs, and in-process projects that no longer qualify are adjusted through opening retained earnings.

Under the retrospective method, prior periods presented are recast as if the new rules had always applied. Each method has different implications for comparability and effort, so organizations should choose based on their circumstances and the needs of the readers of their financial statements.

Examples of ASU 2025-06 in IT Financial Management

The examples below illustrate how the new threshold might apply. They are simplified illustrations, not accounting advice, and organizations should apply the guidance with their auditors.

In both, the key question is not which stage the work is in, but whether management has committed to the project and completion is probable.

A Customer Portal Built With Agile Methods

A company approves and funds a project to build a customer service portal using established technology and well-defined requirements. Development runs in two-week sprints. Under the old rules, the finance team had to decide which sprints counted as application development.

Under ASU 2025-06, once management authorizes and funds the project and completion is probable, eligible development costs are capitalized without assigning each sprint to a stage. Planning, coding and testing costs within the project are evaluated under the same threshold.

An Experimental AI Tool

A company funds a project to build an internal tool using a new machine learning approach that it has not used before, with performance requirements that are still being defined. There is significant development uncertainty, because the core technology has not been proven through coding and testing.

Under the update, capitalization is deferred and costs are expensed until the uncertainty is resolved, for example once a working prototype demonstrates the approach and requirements are stable. Costs incurred after that point may be capitalized if the other conditions are met.

Conclusion

ASU 2025-06 modernizes the accounting for internal-use software under ASC 350-40. It removes the old project stages and replaces them with a threshold based on management authorization, funding commitment and the probability of completion, with capitalization deferred when significant development uncertainty exists.

For IT financial management, the update simplifies capitalization for agile development but changes how and when software costs reach the balance sheet. Organizations should update their policies, tracking and forecasts well before the effective date, working closely with their auditors to apply the new guidance consistently.